Independent assessment of the Chichester Harbour Management Plan (2019-2014)
Chichester Harbour Conservancy
Paul Tiplady 11 February 2019 Chichester Harbour Management Plan Review Independent Assessment Report
THE CRAGG, SATTERTHWAITE Nr ULVERSTON, CUMBRIA LA12 8LW 01229 860269 [email protected] www.craggatak.co.uk
Contents
Introduction ...... ii 1. Background ...... 1 2. Equality Impact Assessment ...... 1 Does the vision affect any person defined by the Equality Act? ...... 2 Do the policies affect any person defined by the Equality Act? ...... 2 Findings ...... 5 3. Bespoke Sustainability Appraisal ...... 5 Relationship to other policies, plans and programmes ...... 6 Key local environmental pressures ...... 6 Methodology ...... 6 Compatibility within the Management Plan...... 7 Consistency with SA Objectives ...... 9 Monitoring of significant sustainability effects ...... 13 Conclusion ...... 14 4. Habitat Regulations Assessment ...... 15 European sites potentially affected ...... 15 Identifying potential adverse effects of Management Plan Policies ...... 16 Results of the screening appraisal ...... 17 Other relevant plans ...... 18 Conclusions ...... 18 Appendices ...... 19 Appendix 1: Management Plan Vision and Policies ...... 19 Appendix 2: Equalities Impact Assessment Framework ...... 21 Appendix 3: Other Plans and Programmes ...... 22
i | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 4: Pressures and outcomes without mitigating actions ...... 24 Appendix 5: Sustainability Appraisal Framework ...... 25 Appendix 6: Key indicators and data sources ...... 28 Appendix 7: HRA programme and methodology ...... 30 Appendix 8: Prioritised issues for European sites within the Solent ...... 34 Appendix 9: Classifying no negative effects on European Sites ...... 37
Introduction
This report has been prepared as part of the third review and revision of the Chichester Harbour Management Plan; the integrated coastal zone management plan for the Trust Port and Area of Outstanding Natural Beauty (AONB). We have considered the vision and 15 policies of the plan (see Appendix 1) and completed the following independent assessments:
• an Equality Impact Assessment; • a Bespoke Sustainability Appraisal; and • an Outline Habitat Regulations Assessment.
Paul Tiplady MRTPI, FLI 11 February 2019
ii | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Location of Chichester Harbour AONB:
iii | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
1. Background
1.1. Looking after Chichester Harbour is vitally important. The 29 square miles of landscape has a delicate balance of interests, from internationally important habitats and species, to a long and proud history of sailing and boat building. With 10,585 residents and an estimated 1.5 million visitors every year, it is essential to have a Management Plan that is fit for now and the future.
1.2. The landscape of the Harbour was formally recognised as being of national importance in 1964 when it was designated an Area of Outstanding Natural Beauty (AONB). Section 82 of the Countryside and Rights of Way (CRoW) Act 2000 establishes the primary purpose of AONB designation as the conservation and enhancement of natural beauty. Under Section 89, the relevant local authorities must prepare and publish a Management Plan for each AONB. CRoW requires a formal review of each Management Plan at intervals of not more than five years. The Management Plan is a statutory document and forms an important part in the delivery of services by the local authorities. AONB Management Plans are a community led strategy implemented by a partnership of organizations and interested parties.
1.3. Chichester Harbour Conservancy was established by the Chichester Harbour Conservancy Act 1971. The Act recognised the Harbour is a single estuary and brought together its management through a Statutory Advisory Committee, made-up of local stakeholders, and a Statutory Board, made-up of local councillors and representatives of the Statutory Advisory Committee. There are four relevant local authorities for the Chichester Harbour AONB. They are Hampshire County Council, West Sussex County Council, Havant Borough Council and Chichester District Council.
1.4. Chichester Harbour Conservancy is a unique organisation. It is the only Statutory Harbour Authority with responsibility for an Area of Outstanding Natural Beauty (AONB). Its purposes extend beyond that of other AONBs, to include leisure, recreation and the conservation of nature. Chichester Harbour Conservancy has a duty to prepare the AONB Management Plan as the framework for the delivery of the statutory purposes and duty.
2. Equality Impact Assessment
2.1. The Equality Act 2010 aims to ensure that everyone has a fair chance in life. It contains a requirement for Local Authorities to consider the diverse needs and requirements of the communities in their areas when planning the services they offer. The Act does not apply to Chichester Harbour Conservancy. However, the management plan has the potential to affect all the people living, working, visiting or carrying out business in the designated area. The Conservancy wishes to ensure that the Vision and Policies do not discriminate in the way service and amenity is provided, and that, where possible, they advance equality of opportunity between people.
2.2. Carrying out an assessment will eliminate or minimise any negative consequences of the plan and maximise the opportunities for promoting equality. The assessment
1 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
considers impacts on nine groups set out in the Equality Act 2010 (see Appendix 2 for the assessment framework):
• Age • Disability • Gender reassignment • Marriage and Civil Partnership • Pregnancy and Maternity • Race / Ethnicity • Religion or belief (including lack of religion or belief) • Sex • Sexual Orientation
2.3. In 2016, the population of Chichester Harbour was 10,585 (living in 5,069 dwellings). Of these, 7,800 are of employment age but only 45% are employed (compared to 61% in the South East). This is likely due to the high number of retired people living in the area (31%, compared to 21% in the South East). There are 455 local businesses and 1.5 million people visit Chichester Harbour every year. In 2018, there were 1,076 responses to survey for the State of the AONB report. This survey found that over 60% of respondents were over 61 and that 66% of survey respondents were male, 32% were female and 1% preferred not to state their gender. The area clearly attracts a narrow range of people than usually found in the South East. The first task was to find if the plan excludes any particular people.
Does the vision affect any person defined by the Equality Act?
2.4. The Management Plan is a combined plan for the Harbour Authority and the AONB. As such, it is limited in scope; its purpose is the conservation, maintenance and improvement of the Harbour and the Amenity Area for recreation and leisure, nature conservation and natural beauty. It cannot direct planning or social policy but it can deliver relevant strategies for other public bodies. It does have a direct impact on recreation, enjoyment and the management of the area as a harbour.
2.5. The Vision includes the aspiration to enable both local people and visitors to enjoy the Harbour, with mutual respect shown by different user groups. The plan also sets out the values that underpin this vision. There is to be an increase in community involvement, public participation and social inclusion in the management of the harbour. This includes enjoyment by users of all ages, abilities and interests. There is to be support for the economic and social needs of the local communities in as far as the designations allow.
2.6. There is no evidence to indicate that the Vision would cause a differential impact on people defined by the Equality Act.
Do the policies affect any person defined by the Equality Act?
2.7. Each policy was tested against the nine equality characteristics: Policy 1 Conserving and Enhancing the Landscape
2 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
The policy seeks to conserve and enhance the landscape character for the benefit of current and future generations. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act. Policy 2 Development Management (supported by 18 Planning Principles) The policy seeks to ensure that all development in Chichester Harbour conserves and enhances the AONB and be consistent with all other designations. The AONB has a higher proportion of older residents and visitors than the wider region. Older people do need good access to services, particularly community and health facilities. It is important that, where possible, these are accessible by public transport or within walking distance. The Conservancy is not the planning authority but it is a non- statutory consultee on planning applications. The Conservancy is not the Social Services or Health body. The policy’s clear intent is to support good practice in the application of rural planning policy. There is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act. Policy 3 Diversity of Habitats The policy seeks to allow natural processes to operate. Aside from natural processes, the intent is for there to be no net area loss of habitats and wherever possible, a net environmental gain. There are actions to restrict access to certain sites but this would apply to all. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act. Policy 4 Safety on the Water The policy seeks to safeguard the harbour and its users by compliance with the Port Marine Safety Code. This complies with legislation and applies equally to all. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act Policy 5 Facilitating Navigation The policy seeks to conserve the Harbour so that it is fit for use as a port. This complies with legislation and applies equally to all. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act Policy 6 Water Quality The policy seeks clean water appropriate to the high conservation value and recreational use of the AONB. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act. Policy 7 Catchment Sensitive Farming The policy seeks an industry that is managed so that it benefits the landscape and biodiversity of the AONB. There is an action to investigate opportunities to better connect young people to farming. There is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on young people. Policy 8 Thriving Wildlife The policy seeks to allow wildlife and plants to flourish and live in harmony with humans. There will be initiatives to moderate recreational activities for the benefit of
3 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
wildlife. This is not aimed at any particular users. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act. Policy 9 Health and Wellbeing The policy seeks to encourage people to exercise, rest and relax. There are actions to improve access for people with restricted mobility and socially excluded groups; and to promote opportunities for visitors to access the area sustainably through reduced car use and improved public transport and cycling links. It may be that positive statements about access for push-chairs would help child carers. It is still the case that women tend to undertake the majority of childcare. They would be more likely to benefit from services and leisure opportunities close to their home. However, there is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on older people and people with a disability.
Policy 10 Enjoying Sailing and Boating The policy seeks to deliver a safe and peaceful estuary for the enjoyment of sailing and boating. Water skiing, kite surfing and similar activities are banned. These may affect young people more than others but the intent is to manage a restrict water space. There is an action to enable people to access the water that would otherwise not be able to. It is unlikely that this policy would cause a differential impact on people defined by the Equality Act; it is possible that there could be a positive impact on people defined under the nine equality characteristics. Policy 11 Excellence in Education The policy seeks to make the harbour a place where people of all ages and abilities can develop an understanding and appreciation of a cherished landscape. There are actions to support special needs groups, build new relationships with local schools that are not currently visiting the Harbour; and to work with new customers to try and overcome any barriers to engagement with the Harbour (such as access and affordability). There is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on people defined under the nine equality characteristics. Policy 12 Connecting People with Nature The policy seeks to maintain Chichester Harbour as a place where people develop relationships with the natural environment. There are actions to develop websites and social media platforms. These might encourage use by a wider range of ages and ethnic groups. There is a specific action to develop new initiatives and activities to help all members of the community, including young people, people with restricted mobility and those who are socially/economically disadvantaged, experience Chichester Harbour. There is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on a wider range of ethnic groups, young people and people with a disability. Policy 13 Prosperous Economy The policy seeks a harbour where marine businesses prosper. It includes an action encourage the take-up of apprenticeships, this make benefit young people. Women
4 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
still tend to undertake the majority of childcare. They would be more likely to benefit from employment opportunities close to their home. However, there is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on younger people. Policy 14 Marine Litter Pollution The policy seeks to reduce marine litter pollution and maintain the rural character of the area. There is no evidence to indicate that this policy would cause a differential impact on people defined by the Equality Act. Policy 15 Historic Environment and Heritage Assets The policy seeks the proper management and appreciation of the heritage assets. There is an action to increase the use of social media. These might encourage use by a wider range of ages and ethnic groups. There is no evidence to indicate that this policy would cause a negative impact on people defined by the Equality Act; there could be a positive impact on a wider range of ethnic groups and young people.
Findings
2.8. There is no evidence to indicate that the Management Plan would cause a differential impact on people defined under the nine equality characteristics.
3. Bespoke Sustainability Appraisal
3.1. An essential consideration when drawing up a management plan for an area is the effect that the policies of the plan are likely to have on the environment and people’s quality of life, both now and in the future. An assessment of these effects is through the process of Sustainability Appraisal (SA).
3.2. Planning Authorities are required to follow a formal assessment under the Planning and Compulsory Purchase Act 2004. Their approach to SA incorporates fully the requirements of the European Directive 2001/42/EC1 on Strategic Environmental Assessment (SEA) and the Environmental Assessment of Plans and Programmes Regulations 20042.
3.3. Chichester Harbour Conservancy is not required to complete a SA for its Management Plan but it does have some obligations under the SEA Directives. The Conservancy requires a light-touch Sustainability Assessment, as part of the review and revision of the Chichester Harbour Management Plan for the Trust Port and Area of Outstanding Natural Beauty (AONB). This will follow the disciplines of the formal SA/SEA regulations but not the full process. There is no consideration of alternative policies, nor is there a testing of baseline data. But it does test the sustainability and logic of the emerging policy cascade.
1 European Directive 2001/42/EC “on the assessment of the effects of certain plans and programmes on the environment”, known as the Strategic Environmental Assessment or SEA Directive. 2 SEA Directive, 2001/42 transposed into English law through the ‘Environmental Assessment of Plans and Programmes Regulations 2004’ (Statutory Instrument No 1633)
5 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Relationship to other policies, plans and programmes
3.4. A key element in the SA process is to review relevant international, national, regional and local policy guidance, plans and strategies, in order to: • Ensure the Management Plan proposals and the SA are consistent with and comply with the requirements of relevant plans and policies, especially where they refer to environmental priorities; • Identify environmental objectives, key targets and indicators that should be reflected in the SA; • Provide evidence for the SA rationale. See Appendix 3 for a list of the documents reviewed.
Key local environmental pressures
3.5. The SEA Directive requires detailed baseline information to be gathered as part of the assessment process. Information must be gathered on “relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan” and the “environmental characteristics of the areas likely to be significantly affected” (Annex I (b) & (c)).
3.6. The baseline data is also required to highlight “any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC (Birds Directive) and 92/43/EEC (Habitats Directive)” (Annex I (c)).
3.7. To assess future trends there is a need to establish a baseline. The AONB team maintains a State of the AONB Report that presents an assessment of the area’s condition and the forces for change. For developing this SA Report, we use the State of the AONB Reports, Natural England’s State of the Environment (South East) Report, Natural England’s National Character Area Profile 126 (South Coast Plain) and the evidence-base attached to the preparation of the local authority Local Development Plans.
3.8. The key pressures associated with the environmental trends within the area are shown in Appendix 4.
Methodology
3.9. Step 1 is to consider the Management Plan text and test the compatibility of its vision and the 15 policies. The intent is to identify potential tensions or sensitivities where two or more policies interact. We collect the findings in a Compatibility Matrix and summarise them in a chart. Using professional judgement, each relationship is plotted as:
++ = strongly positive + = positive but some opportunity for improvement
6 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
0 = neutral +? = some positive but potentially some negative - = negative -- = strongly negative
A commentary develops the findings to take account of the varying environmental sensitivities of the different topic areas.
3.10. Step 2 is to check the vision and each policy against a range of SA Objectives (see Appendix 5 for the SA framework). The intent is to measure the significance of the effect in terms of:
• Beneficial or adverse effects; • Magnitude of the effects; • Reversible or irreversible effects. The findings emerge in a Consistency Matrix. A plot of each relationship uses the same discipline as for the Compatibility Matrix.
3.11. Step 3 is to present a set of Performance Indicators with reference to Schedule 2 of the SEA Regulations on the following topics:
• Landscape • Biodiversity • Water • Cultural Heritage • Access Enjoyment and Understanding • Population and Community • Tourism and Local Economy • Agriculture and Landscape Management • Development and Infrastructure This will provide the basis for predicting and monitoring effects and will help to identify sustainability problems and alternative ways of dealing with them.
3.12. Finally, Conclusions are drawn and presented.
Compatibility within the Management Plan
3.13. The first task is to check the Vision and each Policy of the management plan against each other to see whether there were any potential tensions or sensitivities arising where two or more interact. The inter-policy analysis is in a Compatibility Matrix. The Vision and a full list of policies are set out in Appendix 1.
7 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
3.14. Simple word tracking shows that the Polices pick up all the intent of the Vision. Analysis, using professional judgement confirms that no Policy is in conflict with the Vision. The Vision and Policies are compatible.
3.15. The Policies show few tensions or sensitivities between them. Table 1 shows the findings. The data runs both horizontally and vertically. The grey squares are where each separate policy meets and is not a part of the assessment. Squares close to the grey band represent policies that lie together in the plan. There are no negative impacts but there are 28 uncertain impacts. It is important to consider the strong positive relationships. These are what will focus the plan. The long bands of green in Table 1 suggest that there are some strong links with certain policies. This is clearer in Chart 1; a chart showing the indicative strengths of each policy.
3.16. There is very little difference between the policies, none work in isolation. This suggests a balanced plan.
3.17. Policy 5 (Facilitating Navigation) shows the least compatibility. This is no surprise, as the policy has a very specific and narrow purpose. Policy 1 (Conserving & Enhancing the Landscape) has the strongest relationships with the other policies. This too is no surprise, as it reflects the purpose of AONB designation. Sustainability is supported
8 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
through the strong relations shown by the biodiversity, well-being and development management policies.
Consistency with SA Objectives
3.18. The next task is to check the proposed Vision and Policies of the management plan against the SA Objectives.
The Vision
3.19. The Vision is wide ranging and open in its style whereas the SA Objectives are tightly focused; comparison is difficult. However, the Vision is generally consistent with the SA Objectives, as indicated in Table 2.
The Policies
3.20. The interaction of the Policies with the Objectives is in a Consistency Matrix. This is to see whether there were any significant beneficial or adverse effects; and to gage the magnitude of that effect. Where appropriate, there is consideration as to whether the effect is reversible. Table 3 supports this analysis.
3.21. A number of strong relationships between the Management Plan Policies and the SA Objectives stand out. There are no negative impacts but quite a few instances of minimal or no impact on the SA objectives. It is useful to consider the material in Table 3 in two ways.
9 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
3.22. Firstly, to study the interactions of each plan policy against the combination of the SA Objectives (Chart 2); and then of the combination of each policy against each SA Objective (Chart 3).
Consistency of Management Plan Policies to combined SA Objectives
3.23. All the Management Plan Policies are consistent with the combined SA Objectives, albeit to varying degrees: Policy 1 Conserving and Enhancing the Landscape – has a high level of consistency with the SA Objectives in combination. There are no uncertain relationships.
Policy 2 Development Management – has the highest level of consistency with the SA Objectives in combination, with no uncertain relationships. Eighteen planning principles that tie in well to the SA Objectives underpin this policy. Given the topic, this policy will moderate a number of decisions in the AONB that will affect sustainability
Policy 3 Diversity of Habitats – has a high level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO4 (health) and SAO8 (heritage), which is not a surprise given the clear focus on biodiversity.
Policy 4 Safety on the Water – has a moderate level of consistency with the SA Objectives in combination. There are no uncertain relationships. The policy does not
10 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
link to a number of SA Objectives. This is not a surprise, given the very specific focus of the policy. No modification of the policy is needed.
Policy 5 Facilitating Navigation – has a moderate level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO3 (economic) and SAO5 (water). Again, the policy does not link to a number of SA Objectives. This is not a surprise, given the very specific focus of the policy. No modification of the policy is needed.
Policy 6 Water Quality – has a high level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO2 (communities), SAO3 (economic) and SAO7 (Climate), which is not a surprise, given the narrow focus on water management.
Policy 7 Catchment Sensitive Farming – has a high level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO2 (communities), SAO4 (health) and SAO8 (heritage), which is not a surprise, given the narrow focus on land management. It would be possible to make the policy more consistent with heritage with reference to policies proposed by Heritage England to protect hidden assets.
Policy 8 Thriving Wildlife – has a reasonable level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO3 (economic), SAO4 (health) and SAO9 (landscape). Again, this is not a surprise given the clear focus on biodiversity.
Policy 9 Health and Wellbeing – has a reasonable level of consistency with the SA Objectives in combination. There is a positive but uncertain relationship with SAO7 (climate). The weak link to climate is a surprise but is likely due to the way the SA Objective has been framed with very specific requirements. No modification of the policy is needed.
Policy 10 Enjoying Sailing – has a moderate level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO4 (health) SAO6 (air) and SAO7 (climate). This is not a surprise, given the very specific focus of the policy. No modification of the policy is needed.
Policy 11 Excellence in Education – has a relatively low (though positive) level of consistency with the SA Objectives in combination. It is the least consistent policy.
11 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
There are no uncertain relationships but many where there is no interaction. The policy has a very narrow and specific purpose. It is likely that the benefits that people gain from this policy do link into each SA Objectives but these cannot show up in the assessment. Given the strong relationships shown by the other policies, there is no need to modify the policy.
Policy 12 Connecting People with Nature – has a reasonable level of consistency with the SA Objectives in combination. There is a positive but uncertain relationship with SAO9 (landscape). This does seem odd but the policy does focus tightly on wildlife. No modification of the policy is needed.
Policy 13 Prosperous Economy – has a high level of consistency with the SA Objectives in combination. There is one positive but uncertain relationship. Surprisingly, this is with SAO9 (landscape). There is no link to SAO6 (air). However, the other relationships are strong. No modification of the policy is needed.
Policy 14 Marine Litter Pollution – has a reasonable level of consistency with the SA Objectives in combination. There are positive but uncertain relationships with SAO2 (communities) and SAO5 (water). The overall relationship is good.
Policy 15 Historic Environment and Heritage Assets – has a moderate level of consistency with the SA Objectives in combination, there are no uncertain relationships. The policy does not link to a number of SA Objectives. The policy supports SAO2 (communities), SAO8 (heritage) and SAO9 (landscape), which is to be expected.
Consistency of combined Management Plan Policies to SA Objectives
3.24. Each SA Objective gains support from the Management Plan Policies operating in combination: SAO1 Prevent loss of and enhance habitats - has a high level of consistency with the policies in combination. There are no uncertain relationships. SAO2 Support sustainable communities - has a high level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 6 (Water Quality), Policy 7 (Catchment Sensitive Farming) and Policy 14 (Marine Litter Pollution). The uncertain link to farming is a surprise but is not a concern. SAO3 Support sustainable economic development - has a reasonable level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 5 (Facilitating Navigation), Policy 6 (Water Quality) and Policy 8 (Thriving Wildlife). There are also a number of policies with no interaction. The
12 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
AONB is not an economic development designation though there is a duty to support communities. Given that the business and planning policies score well, there is no need to modify the plan.
SAO4 Safeguard and enhance human health - has a high level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 3 (Diversity of Habitats), Policy 7 (Catchment Sensitive Farming), Policy 8 (Thriving Wildlife), Policy 10 (Enjoying Sailing and Boating) and Policy 12 (Connecting People with Nature). This is not a surprise given the definition of the topic.
SAO5 Maintain and improve water quality and use water efficiently and protect water resources - has a reasonable level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 5 (Facilitating Navigation) and Policy 14 (Marine Litter Pollution). This is not a surprise given the definition of the topic.
SAO6 Maintain quality of Air – has a relatively low (though positive) level of consistency with the policies in combination. This is because there are few interactions. The Management Plan does not seek to improve air quality and it is not clear how it could. The emphasis on sailing rather than motorised sports does modify air-born pollutants.
SAO7 Address the causes and consequences of climate change with particular focus on improving resilience and adaptation - has a reasonable level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 6 (Water Quality), Policy 9 (Health & Wellbeing), Policy 10 (Enjoying Sailing and Boating) and Policy 12 (Connecting People with Nature). This is not a surprise given the definition of the topic.
SAO8 Maintain and enhance cultural heritage, including architectural and archaeological heritage adaptation - has a reasonable level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 3 (Diversity of Habitats) and Policy 7 (Catchment Sensitive Farming). Though there is no need to modify the plan, it is of some concern that there is an uncertain relationship between Heritage and Agriculture, with a potential risk to hidden heritage assets.
SAO9 Protect and enhance the landscape – has the highest level of consistency with the policies in combination. There are positive but uncertain relationships with Policy 8 (Thriving Wildlife) and Policy 13 (Prosperous Economy). But overall, the consistency is strong and there is no need to modify the plan.
SAO10 Support a more sustainable means of production and use of resources- has a reasonable level of consistency with the policies in combination. There are no uncertain relationships but there are a number of policies with no interaction. This is not a surprise given the definition of the topic. The strengths lie with water, asset management and planning.
Monitoring of significant sustainability effects
13 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
3.25. The SA of the draft management plan has identified no significant adverse effects that are likely to arise from the implementation of management plan. Some significant positive effects are likely to arise from the implementation of the plan. The assessment has also identified some areas of uncertainty over the significance of some of the predicted effects and monitoring will cover these effects as well.
3.26. We identify 63 potential indicators to monitor the sustainability effects of implementing the Management Plan, 50 of which are already in the State of the AONB and a further 2 are actions in the Management Plan. The indicators are described Appendix 6.
Conclusion
3.27. The Management Plan has 15 Policies. The Vision and proposed policies are compatible. There are no tensions or sensitivities arising from where two or more interact. The proposed policy cascade has a beneficial, and in parts, a significantly beneficial, effect on the SA Objectives.
3.28. There are a few surprises, though, in the consistency of each policy with the combined SA Objectives. The strongest relationships were with Development Management and Prosperous Economy. This suggests a very sustainable approach to the Harbour management. Catchment Sensitive Farming shows a high level of consistency with the SA Objectives but does not refer to protecting heritage assets, though it is implied. It would be possible to strengthen this relationship. Education shows the weakest relationship with the combined SA Objectives. This is because the policy has a very narrow and specific purpose. However, this policy shows no uncertain relationships, just many where there is no interaction. It is likely that the benefits that people gain from this policy do link into each SA Objective but there is no evidence of this within the Management Plan. There is no need to modify the plan.
3.29. When analysed in combination, the policies show the greatest consistency with the SA Objectives to conserve and enhance natural beauty, habitats, communities and health. This reflects the purpose of AONB designation. It also suggests that the plan is seeking to deliver the Government’s priorities for the countryside, as set out in ‘A Green Future (2018)’. The weakest relationship is with air quality but there is no need to modify the plan.
3.30. There are no adverse effects on the SA Objectives so there is no need to consider measures to increase the beneficial effects but opportunities exist to do so. There is no recommendation for mitigating actions.
3.31. In conclusion: There is nothing in the management plan that will undermine the special qualities of the Trust Port and AONB. Implementation of the proposed Management Plan will have environmental and sustainability benefits for Chichester Harbour AONB.
14 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
4. Habitat Regulations Assessment
This is the Habitats Regulations Assessment (HRA) Screening Report prepared for the Chichester Harbour Management Plan 2019-2024. The Plan is an integrated coastal zone management strategy for the Trust Port and Area of Outstanding Natural Beauty.
4.1. Habitat Regulations Assessment is a statutory requirement3 to ensure that the protection of the integrity of European sites is a part of the planning process at a regional and local level. Any plan or project not directly connected to the management of the European site but likely to have a significant effect upon it (either individually or in combination with other plans or projects) shall be the subject of an appropriate assessment of its implications for the European site in view of the site’s conservation objective. The plan making body and Natural England must ascertain that the proposed plan or project will not adversely affect the integrity of a European site before agreeing it.
4.2. European sites consist of Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Offshore Marine Site (OMS). It is common practice to treat RAMSAR sites (Internationally Important Wetlands) as if they were European sites. The guidance recommends taking into consideration European sites within the plan area and within 15km of its boundary.
4.3. It is the accepted practice to adopt a stage-by-stage approach to the assessment. Each stage determines whether a further stage in the process is required. There are four stages (see Appendix 7 for a detailed explanation): Stage One: Screening - To identify the likely impacts on a European site of a project or plan, either alone or in combination with other projects or plans, and consider whether these impacts are likely to be significant;
Stage Two: Appropriate Assessment (where there are likely to be significant impacts) - To consider the impact on the integrity of the European site of the project or plan, either alone or ‘in combination’ with other projects or plans, with respect to the structure, function and conservation objectives of the site. Additionally, where there are adverse impacts, to assess the potential mitigation of those impacts; Stage Three: Assessment of alternative solutions - To examine alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the European site;
Stage Four: Assessment where no alternative solutions exist (where adverse impacts remain) - To assess compensatory measures where, in the light of an assessment of imperative reasons of overriding public interest, it is deemed that the project or plan should proceed.
European sites potentially affected
3 Council Directive 92/43/EEC of 21st May 1992 on the conservation of natural habitats and of wild fauna and flora. Transposed into law by the Conservation (Natural Habitats) Regulations 1994 (Habitats Regulation) as amended in 1997 and in 2000 (in England only) as amended in 2017 (SI 1012).
15 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
4.4. Nearly 50% of the AONB is designated as an European site:
• Chichester and Langstone Harbours SPA / RAMSAR • Solent Maritime SAC
4.5. Through an analysis using MAGIC Map4 it was determined that the following European sites are within 15km of the AONB: • Butser Hill SAC • Kingley Vale SAC • Pagham Harbour SPA / RAMSAR • Portsmouth SPA / RAMSAR • Rook Clift SAC • Singleton and Cocking Tunnels SAC • Solent and Isle of Wight Lagoons SAC • Solent and Southampton SPA / RAMSAR • South Wight Maritime SAC
4.6. Descriptions of each European site are set out in a separate Annex. The qualifying features and conservation objectives for each site are set out in a schedule, as stated by Natural England.
Identifying potential adverse effects of Management Plan Policies
4.7. To understand whether the Management Plan may affect the European sites listed above it is necessary to identify those factors that will adversely affect the sites. Through Natural England, data is available for each European site on the conservation objectives and definitions of favourable condition for the designated features of interest complete with a statement on the current pressures that threaten their integrity.
4.8. Natural England produces Site Improvement Plans (SIPs) for each European site in England, developed as part of the Improvement Programme for England's European sites. The plans are not legal documents; they are live documents capable of updating to reflect changes in evidence / knowledge and as actions get underway.
4.9. The SIPs for sites within the AONB provide an overview of the issues (both current and predicted) affecting the condition of the SACs. They also outline the priority measures required to improve the condition of the features. They do not cover issues where remedial actions are already in place or ongoing management activities that are required for maintenance.
4.10. These pressures are summarised in Table 4, ranked in Natural England’s order of priority.
Table 4: Pressures that threaten the integrity of the European sites For the coastal sites: For the inland sites:
4 The Government’s open-access mapping service at http://magic.gov.uk/
16 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
1. Air pollution: impact of atmospheric 1. Agriculture: other nitrogen deposition 2. Air pollution: impact of atmospheric 2. Biological resource use nitrogen deposition 3. Change in land management 3. Deer 4. Change to site conditions 4. Forestry and woodland management 5. Changes in species distribution 5. Habitat connectivity 6. Climate change 6. Habitat fragmentation 7. Coastal squeeze 7. Inappropriate scrub control 8. Direct impact from 3rd party 8. Large-leaved lime location/ extent/ 9. Direct land-take from development condition unknown 10. Extraction: non-living resources 9. Public access / disturbance 11. Fisheries: commercial marine and 10. Undergrazing estuarine 12. Fisheries: recreational marine and estuarine 13. Hydrological changes 14. Inappropriate coastal management 15. Inappropriate pest control 16. Inappropriate weed control 17. Invasive species 18. Physical modification 19. Public access / disturbance 20. Water pollution
4.11. Supporting explanations are set out for the Solent sites in Appendix 8. The factors listed in the European site schedules frame the testing of policies within the Trust Port and AONB Management Plan when assessing their effect upon each site.
Results of the screening appraisal
4.12. Task 1 is to compile a schedule listing all the policies of the Management Plan and check each for the likelihood of it leading to a significant effect on a European site (Appendix 9). The initial task was to identify those objectives and actions that have no negative effects (Category A).
4.13. The assessment applies the precautionary principle. An element is screened when it has the potential for one or more of the impacts, even if it falls under an element that does not have that impact. Where no potential ecological impacts have been identified, it has been assumed that the policy or action will not have an impact on a European site.
4.14. Some of the European sites are at risk from outdoor sports, leisure and recreational activities. Chichester Harbour is one of the busiest recreational harbours in the country. Policy 9 Health and Wellbeing seeks to encourage the recreational use of the Harbour. However, the policy includes the caveat that this will be in ways that respect nature. Therefore, Policy 9 is very unlikely to have any significant effects on the integrity of any European sites.
4.15. The preliminary screening finds that no policies in the Management Plan are likely to have any effect on the integrity of any European site.
17 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Other relevant plans
4.16. The Habitats Regulations state that when considering whether a specific plan or project is likely to have a significant effect on a European site, this should consider possible ‘in- combination’ effects with other plans or projects.
4.17. Part of the Management Plan screening process is to identify the plans, programmes and projects that could have ‘in-combination’ effects. There is no assessment of these plans, programmes and projects in any detail at this stage. In-combination effects are only assessed where it is identified in Stage 2 of the HRA process that the Management Plan policies and actions are likely to have significant adverse effects. A series of other plans and projects were identified to test for possible in-combination effects. These are outlined in Appendix 3.
4.18. As the plan is not likely to have an impact on a site, there is no potential for any ‘in- combination’ effect.
Conclusions
4.19. Results of Screening:
• That no policy areas would have an adverse effect on the integrity of any European site.
• There is no requirement to undertake an Appropriate Assessment under the Habitat Regulations.
18 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendices
Appendix 1: Management Plan Vision and Policies
Vision In 2050, the nationally and internationally important landscape and setting of Chichester Harbour is conserved and enhanced. • The special qualities of the Area of Outstanding Natural Beauty are appreciated and enjoyed by local people and visitors who care for the Harbour now and in the future. • Management is balanced by ongoing mutual respect shown by different user groups and all within the natural limits of the Harbour. • The diverse habitats and excellent water quality benefit the rich array of wildlife, which use the Harbour in harmony with the recreational activities of sailing, walking, cycling and relaxing. • People understand and value their surroundings with many opportunities for outdoor education. • Businesses thrive with marine enterprises, farmers and tourism providers positively contributing towards a prosperous local economy whilst safeguarding the natural and historic environment. Chichester Harbour will be a resilient landscape, where local communities and businesses are prepared and able adapt to future challenges. Policies Policy 1 The distinctive landscape character of Chichester Harbour Area of Conserving and Outstanding Natural Beauty will continue to be conserved and enhanced Enhancing the for the benefit of current and future generations. Landscape Policy 2 All development in Chichester Harbour will continue to conserve and Development enhance the Area of Outstanding Natural Beauty and be consistent with all Management other designations. Determinations on applications for planning permission and forms of consent will be consistent with the relevant policies of the relevant adopted Local Plan. Development outside of the Area of Outstanding Natural Beauty, but sufficiently close to the boundary, will not detrimentally impact the character and setting of the protected landscape. Mitigation for recreational disturbance will be sought for all new developments within 5.6 kilometres of the Special Protection Area. The Chichester Harbour Planning Principles are designed to help applicants understand the criteria against which planning applications will be assessed in and Supported by 18 around Chichester Harbour AONB by Chichester Harbour Conservancy. The Planning Principles Planning Principles will be used to decide whether or not to raise an objection to any given planning application. Policy 3 Diversity of The richness of the Harbour’s natural habitats will continue to be Habitats conserved, restored and enhanced so wildlife can thrive and ecological systems remain healthy and valued. Aside from natural processes, there will be no net area loss of habitats in Chichester Harbour. With regards to any relevant new developments, the statutory obligation for net environment gains will be implemented. Policy 4 Safety on Chichester Harbour Conservancy will undertake and regulate marine the Water operations in a way that safeguards the Harbour, its users, the public and the environment, by implementing and demonstrating compliance with the Port Marine Safety Code.
19 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Policy 5 Facilitating Chichester Harbour Conservancy will continue to conserve the Harbour so Navigation that it is fit for use as a Trust Port. Users will be provided with adequate information about conditions in the Harbour. Policy 6 Water The water of Chichester Harbour will be appropriate to the high Quality conservation value and recreational use of the Area of Outstanding Natural Beauty. Work will continue to manage sources of water pollution. Waste reception facilities will continue to be provided and oil spill response preparedness will be maintained. Research into pollution, including microplastics, will be undertaken. Policy 7 Catchment The farms and water catchments surrounding Chichester Harbour are the Sensitive Farming dominant landform of the Area of Outstanding Natural Beauty. They will continue to be sustainably managed to protect the nationally important landscape designation and promote biodiversity Policy 8 Thriving The abundant wildlife and plants of Chichester Harbour will continue to be Wildlife cherished, respected, allowed space to flourish, and will live in harmony with humans. Ongoing species research will continue to help inform management decisions. Policy 9 Health and Chichester Harbour will continue to be recognised as an exceptional place Wellbeing for people undertake outdoor exercise. The landscape will continue to be enjoyed by walkers, cyclists, sailors and boaters, with opportunities available to try water sports, like kayaking, canoeing, stand-up paddleboarding and rowing in ways that respect nature. For many others, the chance to simply rest and relax in an Area of Outstanding Natural Beauty will benefit everyday wellbeing. Policy 10 Enjoying Chichester Harbour is one of the busiest recreational harbours in the Sailing and Boating country. The estuary will continue to be managed for the peaceful enjoyment of sailing and boating. Policy 11 The stunning estuary of Chichester Harbour is a place where people of all Excellence in ages and abilities can develop an understanding and appreciation of one of Education England’s most cherished landscapes. The Chichester Harbour Education Service will continue to work with visiting schools and colleges, thereby enabling children and young people to learn about the Area of Outstanding Natural Beauty. Policy 12 Local communities are fundamentally important to Chichester Harbour and Connecting People the long-term protection of the Area of Outstanding Natural Beauty. with Nature Chichester Harbour will continue to be a place where people develop positive relationships with the natural environment, thereby fostering a long-term sense of guardianship. Policy 13 Chichester Harbour will continue to be a place where marine businesses Prosperous prosper. Everyday working practices respect the importance of the Area of Economy Outstanding Natural Beauty designation and the range of other environmental and historic designations. Policy 14 Marine Global marine litter pollution has increased substantially in recent years, Litter Pollution with a high level of public awareness. Chichester Harbour will continue to be part of the solution by maintaining the coastal countryside befitting the Area of Outstanding Natural Beauty designation. Policy 15 Historic The landscape of Chichester Harbour reflects its history. The historic Environment and environment and heritage assets of the Area of Outstanding Natural Beauty Heritage Assets will continue to be conserved and enhanced in keeping with its inherent value, with increased opportunities to access, better understand and appreciate the past.
20 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 2: Equalities Impact Assessment Framework
Public sector duty regarding socio-economic inequalities An authority to which this section applies must, when making decisions of a strategic nature about how to exercise its functions, have due regard to the desirability of exercising them in a way that is designed to reduce the inequalities of outcome which result from socio-economic disadvantage. Equality Act 2010: Section 1 Protected Will the plan help to ...... ? Characteristics Age • reduce exclusion through fear, victimisation and harassment • reduce exclusion through denial on unreasonable grounds of age • make access to services (particularly community and health facilities) easy or difficult • make services accessible by public transport or within walking distance Disability • reduce accessibility barriers for mobility impairments • provide opportunities for sociability, for quiet, and for activities and physical exercise by people with impairments • make access to employment, services and leisure opportunities close to their homes Gender reassignment • reduce exclusion through fear, victimisation and harassment Marriage and Civil • reduce exclusion through denial on grounds of marital status Partnership Pregnancy and • reduce exclusion through fear Maternity • provide buggy-accessible paths, toilets and baby-changing facilities • for mothers, make access to employment, services and leisure opportunities close to their homes Race / Ethnicity • deny segregation by race or ethnicity • ensure income generation doe not exclude low-income users (proportionally more people of black and minority ethnicities are on low incomes in the UK) Religion or belief • reduce exclusion through fear and harassment. • provide private outdoor spaces • provide spaces for single-sex assembly Sex • reduce women’s’ exclusion through fear from open space / countryside • for child-carers (women make up the highest proportion), make access to employment, services and leisure opportunities close to their homes • enable women to breast-feed their child without fear or harassment Sexual Orientation • reduce exclusion through fear, victimisation and harassment
21 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 3: Other Plans and Programmes
European • The Water Framework Directive (2000/60/EC) (2000) • The Strategic Environmental Assessment (SEA) Directive (2001/42/EC) (2001) • The Habitats Directive (Directive on the Conservation of Natural Habitats and Wild Fauna and Flora) (Directive 92/43/EC) (1992) • The Birds Directive (Directive on Conservation of Wild Birds) (79/409/EEC) (Adopted 1979) National • The Conservation (Natural Habitats) Regulations 1994 (Habitats Regulation) as amended in 1997, 2000 (in England only) and 2017 • Countryside and Rights of Way (CRoW) Act 2000 • The Environmental Assessment of Plans and Programmes Regulations 2004 • Natural Environment & Rural Communities Act 2006 • European Union (Notification of Withdrawal) Act 2017 • ‘The Natural Choice’, the Natural Environment White Paper, Department for Environment, Food and Rural Affairs • A Green Future: Our 25 Year Plan to Improve the Environment, HM Government • Health and Harmony: the future for food, farming and the environment in a Green Brexit, Department for Environment, Food and Rural Affairs • Fixing our broken housing market, Department for Communities and Local Government • The Clean Growth Strategy Leading the way to a low carbon future, Department for Business, Energy and Industrial Strategy • Conservation 21: Natural England’s conservation strategy for the 21st century, Natural England • National Character Area Profile: 126 South Coast Plain (NE525), Natural England • State of the natural environment in the South East (NE135), Natural England • Tourism Action Plan, Department for Culture, Media and Sport • Estuary Edges: Ecological Design Advice, Environment Agency • Guidance Notes for the Reduction of Light Pollution, Institution of Lighting Professionals • National Planning Policy Framework, Ministry of Housing, Communities and Local Government • National Planning Policy Guidance, Ministry of Housing, Communities and Local Government • Port Marine Safety Code, Department for Transport • South Inshore Plan, the Marine Management Organisation Solent • North Solent Shoreline Management Plan, Eastern Solent Coastal Partnership • Solent Waders and Brent Goose Strategy, Hampshire and Isle of Wight Wildlife Trust County • Hampshire Minerals and Waste Local Plan, Hampshire County Council • Serving Hampshire, Hampshire County Council • West Sussex Minerals and Waste Local Plan, West Sussex County Council • West Sussex Plan, West Sussex County Council Local • Chichester District Surface Water and Foul Drainage Supplementary Planning Document, Chichester District Council.
22 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
• Chichester Harbour AONB Joint Supplementary Planning Document, Havant Borough Council and Chichester District Council • Chichester Harbour Landscape Character Assessment, Chichester Harbour Conservancy • Chichester Harbour State of the AONB Report, Chichester Harbour Conservancy • Chichester Local Plan, Chichester District Council • Havant Local Plan (Core Strategy), Havant Borough Council • Neighbourhood Plans • Oil Spill Contingency Plan, Chichester Harbour Conservancy • Sustainable Shorelines: General Guidance, Chichester Harbour Conservancy and Royal Haskoning DHV • Village Design Statements
23 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 4: Pressures and outcomes without mitigating actions
Sea level rise and climate change In 2013, the Intergovernmental Panel on Climate Change projected that global sea levels would rise between 0.53 metres and 0.98 metres by 2100. If this is correct, it would have a dramatic impact on Chichester Harbour, most likely affecting the sailing clubs, coastal footpaths, Harbourside buildings and dwellings, lowland farming and network infrastructure (e.g. roads, power supplies, telephone and broadband lines, etc.). Development There are over 300 planning applications submitted every year in and directly around the AONB. The growing trend towards larger and more prominent Harbourside detached houses detracts from the natural beauty. Over-time, the impact of incremental developments is resulting in the gradual urbanisation of the countryside. Movement, lights and sound in the environment can disturb wildlife. High levels of light pollution have a detrimental impact on wildlife. The length of natural coastline in the Harbour is decreasing as more shoreline defences are installed. This causes coastal squeeze - the loss of saltmarsh habitat - and affects the natural setting of the AONB. Water quality and marine pollution New housing developments add pressure on the Waste Water Treatment Works. In addition, high levels of storm discharge from Waste Water Treatment Works can lead to discharge into the Harbour during periods of heavy rainfall. This affects water quality, which can lead to excessive nitrates and the growth of macroalgal weed, a problem for wildlife, water users and local people. Agricultural run-off from farms within the catchment also has a large detrimental impact on water quality. Chichester Harbour is affected by marine pollution, and in particular from plastics. Noise pollution Chichester Harbour is affected by noise pollution from accumulative Harbourside building works, occasional social events and displays, and by recreational activities.
24 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 5: Sustainability Appraisal Framework
Objective Will the plan help to ...... ? SAO1 Habitats • prevent loss of habitat Prevent loss of and enhance habitats • prevent pollution • maintain and enhance access to sites whilst avoiding and reducing adverse impacts • maintain economic activities whilst avoiding and reducing adverse impacts • maintain or increase area of habitat • improve management, linkage and condition of designated habitats • create opportunities to enhance biodiversity • prevent the introduction of non-native invasive species and support their detection and removal SAO2 Communities • ensure the provision of affordable housing Support sustainable communities • improve access to services • improve access to employment • improve access to education and skills • improve access to open space • retain and enhance public transport • secure higher skilled and higher paid employment • promote art, craft and cultural interests SAO3 Economic • support the diversification and long term Support sustainable economic development viability of commercial activities • secure adequate provision of employment land • support the provision of infrastructure, including ICT and transport • support improved business productivity and innovation • support enterprise to address climate change SAO4 Health • reduce and avoid noise pollution Safeguard and enhance human health • reduce and avoid light pollution • deliver adequate provision of infrastructure, including drinking water, sewage disposal and waste management • improve safety • ensure the appropriate management of coastal erosion • increase availability of locally sourced food SAO5 Water • prevent pollution Maintain and improve water quality and use • protect and improve drinking water water efficiently and protect water resources • protect existing groundwater abstractions from derogation by new abstractions
25 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
• increase use of sustainable drainage systems • improve efficiency and conservation in use of water • ensure sufficient water supply for agriculture • protect woodland and promote timber production • compliance with the Water Framework Directive • prevent saline intrusion adversely impacting groundwater and groundwater supplies SAO6 Air • meet national air quality standards Maintain quality of Air • deliver a more sustainable pattern of transport • increase cycling and walking SAO7 Climate • reduce greenhouse gas emissions Address the causes and consequences of • ensure tourism is compatible with the climate change with particular focus on climate change agenda improving resilience and adaptation • improve energy efficiency • improve public transport • increase the use of sustainable design and construction techniques • maximise the role of soil as a carbon store • prevent soil erosion • ensure communities, infrastructure and services are resilient against flood risk, coastal change and drought. • provide space for habitats to migrate inland in response to rising sea levels SAO8 Heritage • protect and enhance architectural heritage Maintain and enhance cultural heritage, • protect and enhance archaeological heritage including architectural and archaeological (including unknown) heritage • protect and enhance cultural heritage • reduce risks to heritage • improve access to historic buildings for residents and visitors • enhance local distinctiveness • protect geodiversity SAO9 Landscape • protect and enhance visual amenity Protect and enhance the landscape • protect and enhance landscape character • protect and enhance seascape character • coastal erosion SAO10 Resources • increase recycling and composting Support a more sustainable means of • promote sustainable timber production production and use of resources • increase the renewable energy capacity • improve efficiency and effectiveness of sewerage system • ensure the efficient use of developed land
26 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
• ensure the sustainable use of mineral resources • increase local food production
27 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 6: Key indicators and data sources
SA Topic Key Indicator5 Source Landscape Levels of tranquillity State of the AONB Report Levels of intrusion AONB Unit/Management Dark night skies Plan Action Local Landscape Character Local Planning Authority Assessments Natural England Fixed point photography6 Biodiversity / Habitat extent and condition State of the AONB Report Geodiversity Presence/numbers of birds (including Sussex Wildlife Trust waders and Brent Geese) Natural England Presence/numbers of fish RSPB Presence/number of common seals Extent and condition of geological features Water Water quality in Chichester Harbour State of the AONB Report Bathing site water quality Environment Agency Water Framework Directive Ecological Status Fluvial flood risk Flood defences Cultural Heritage Number and area of Conservation Areas State of the AONB Report Number and area covered by Scheduled Local Planning Authority Monuments Historic England Number and classification of Listed Buildings Number and location of locally important archaeological sites/features listed on the HER Condition of archaeological features Management of archaeological/historic features through agri-environment schemes Access, Enjoyment Profile of recreational users in the AONB State of AONB Report and Understanding Reasons for visiting the AONB and frequency of visits Attendance of activities organised by the Conservancy Recreational activities undertaken by visitors to the AONB Number and type of boats based in Chichester Harbour Locations of water-based recreation activity Location and total length of public rights of way
5 Bold indicators are collected in the State of the AONB Report 6 Actions under Policy 1 & 2 of the management plan
28 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Footpath condition Number of education sessions delivered by the Conservancy Number of education events carried out by the Conservancy Population and Population trends State of AONB Report Community Patterns in employment and types of Census businesses Indices of Deprivation Levels of deprivation Local Planning Authority Average property values and second home ownership Number of volunteer hours contributed to the work of the Conservancy Outreach activity of the Conservancy Number and type of dwellings Health inequality data Standard Mortality Ratios Disability data Tourism and Local Patterns in employment and types of State of AONB Report Economy businesses Local Planning Authority Origin of visitors/recreational users in the AONB (including distance travelled and mode of transport) Length of stay and accommodation type Estimated value of tourism to the local economy Number of sustainable tourism initiatives delivered Agriculture and Patterns of agricultural land use and State of AONB Report Landscape farm types DEFRA Management Livestock numbers and types Natural England Areas of land under agri-environment Forestry Commission schemes
Field patterns Field boundary condition Extent and Type of woodland cover Extent of recent woodland planting Woodland management Development and Number of planning applications State of AONB Report Infrastructure requiring AONB recommendation AONB Partnership Number of improvements made to water Local Planning Authority infrastructure. Waste disposal authorities Number of improvements made to and waste planning sewerage treatment facilities authorities Increase in recyclable opportunities across the Harbour Number of renewable energy installations/projects across the Harbour.
29 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 7: HRA programme and methodology
Introduction
The approach for carrying out the HRA of the Management Plan Review is based on good practice and the following guidance:
• European Commission (2001). Assessment of plans and projects significantly affecting Natura 2000 sites • European Commission (2002). Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/ECC • Department for Communities and Local Government (2006). Planning for the Protection of European Sites: Appropriate Assessment. Guidance for Regional Spatial Strategies and Local Development Documents. • European Commission (2007). Managing Natura 2000 sites: The provisions of Article 6 of the Habitats Directive 92/43/ECC • The Conservation (Natural Habitats) Regulations 1994 (Habitats Regulation) as amended in 1997 and in 2000 (in England only) as amended in 2017 (SI 1012). A summary of the approach and method applied to the Management Plan is set out in Table A below:
Table A: The four stages of assessment Habitats Stages / Tasks Description Directive Analyse the European site(s) and the i reasons for designation, and the underlying trends affecting it (them) Likely Significant Effects or 1 ‘Screening’ Assess whether the policies and associated actions either alone or in combination with ii other plans are able to have a significant impact on the site(s). Where a significant impact is likely: Analyse the policy, including key components i and how the actions would be implemented in practice Article Analyse other plans and projects that could 6(3) ii contribute to ‘in combination’ effects Analyse how the policies and actions in iii combination with other plans and projects will 2 Appropriate Assessment ‘interact’ with implementation Where applicable, propose and assess iv mitigation measures for addressing adverse effects Prepare an Appropriate Assessment Report v for consultation with national agency and key stakeholders Reassess alternatives if effective mitigation Assessment of Alternative proves impossible and develop / select a 3 - Solutions different alternative that does not harm site integrity.
30 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
At this stage actions which, even with i mitigation, still have an adverse effect on the site(s) integrity should be dropped. Assessment where no Assess whether an action can be passed alternative solutions remain Article 4 ii justified by ‘imperative reasons of overriding and where adverse impacts 6(4) public interest’. remain Permitted on the grounds of human health, public safety or primary beneficial consequences for the environment.
Pre-Screening
Gather information on the location of the plan area and the scope and intent of its draft Management Plan. This includes the location, conservation objectives and qualifying feature(s) for each European site complete with the key factors influencing that condition; and the objectives of other plans and schemes in the area that may work in combination with the Management Plan to affect a European site.
Stage one – Screening for a likely significant effect
Categorise each element of the plan as to its likely effects on each interest feature of each European site identified as subject to assessment in the evidence base. This includes all of the reasons for the designation / classification or listing of the site (in the case of SAC, including primary and non-primary reasons for designation). There are four categories of potential effects as follows:
Category A: elements of the plan that would have no negative effect7 on a European site at all; Category B: elements of the plan that could have an effect but the likelihood is there would be no significant negative effect on a European site either alone or in combination with other elements of the same plan, or other plans or projects; Category C: elements of the plan that could or would be likely to have a significant effect alone and will require the plan to be subject to an appropriate assessment before the plan may be adopted; Category D: elements of the plan that would be likely to have a significant effect in combination with other elements of the same plan, or other plans or projects and will require the plan to be subject to an appropriate assessment before the plan may be adopted; After Tyldesley, D. CCW 2012 The European Court of Justice has ruled that only effects that could undermine the conservation objectives of a European site are likely to have significant effects. Therefore, the initial task is to identify those policies and actions that have no negative effects (Category A). There are likely to be five types of policies and actions in the plan that could have no negative effects at all on any European site (either alone or in combination with
7 ‘Negative’ effects in the context of this and all the following lists are effects that would be likely to undermine the conservation objectives of a European site. (Tyldesley, D., 2012 ‘Final Draft Guidance for Plan Making Authorities in Wales: The Appraisal of Plans under the Habitats Regulations’ by David Tyldesley and Associates for Countryside Council for Wales, September 2012. footnote 24)
31 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report other policies, plans or projects). They include the general statements of policy that the EC has indicated could not have a significant effect on a site. The five types are as follows:
A1 Options / policies that will not themselves lead to development e.g. because they relate to design or other qualitative criteria for development; or they are not a land use planning policy. A2 Options / policies intended to protect the natural environment, including biodiversity. A3 Options / policies intended to conserve or enhance the natural, built or historic environment, where enhancement measures will not be likely to have any negative effect on a European site. A4 Options / policies that positively steer development away from European sites and associated sensitive areas. A5 General policy statements or policies only expressing general intentions or political aspirations. After Tyldesley, D. CCW 2012 There are three tasks in Step One: Task 1 – Compile a schedule listing all the policies and actions of the Management Plan. Check each element for the likelihood of it leading to a significant effect on a European site.
All elements placed in Category A are set aside, as they could have no ecological impact on any European site. Those elements identified as having a potential negative impact upon any European site were re-checked ‘in combination’ with other elements of the Management Plan. Where other elements clearly mitigated any potential negative impacts, they are set aside. Task 2 – Assess the remaining elements of the plan for each European site (both alone and in combination) to identify any elements that could have an effect but would not be likely to have a significant (negative) effect on a European site because the effects are trivial or ‘de minimis’, even if combined with other effects (Category B). The identification of such elements follows the precautionary principle. If there is any doubt about an ecological impact then the element remains in the assessment process.
All elements placed in Category B are set aside, as they could have no ecological impact on any European site. Task 3 - Any remaining elements are likely to have a significant effect alone (Category C) or in combination (Category D).
Move to Step Three
Stage Two – Appropriate Assessment
Once identified as Category C or D, the recommendation is to remove the policy or action from the plan, or otherwise modify the plan, to avoid the likelihood of significant effects (all modifications pass through the assessment steps).
32 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Where modification is not possible, the plan must be the subject of a full appropriate assessment.
Stage Three: Assessment of alternative solutions
To examine alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the European site;
Stage Four: Assessment where no alternative solutions exist (where adverse impacts remain)
To assess compensatory measures where, in the light of an assessment of imperative reasons of overriding public interest, it is deemed that the project or plan should proceed.
Consultation and re-appraisal
The draft Management Plan and Habitats Regulations Screening Report are the subject of consultation with the Natural England. Amendments to the Management Plan may occur in the light of the Screening Report and Sustainability Appraisal / Strategic Environmental Assessment findings and / or the advice received from the statutory agencies. The plan making authority should remove potentially harmful policies and proposals and explicitly include measures to ensure that no development flowing from the plan will have an adverse effect on the integrity of a European site. The plan making authority must consult and reach agreement with Natural England before concluding that a plan would have no adverse effect on the integrity of a European site. If the plan making authority amends the Management Plan, then there is a reappraisal of the impacts upon the integrity of any Natura 2000 sites under the Habitat Regulations using the methodology set out above.
33 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 8: Prioritised issues for European sites within the Solent
The Solent Site Improvement Plan (SIP) covers the Solent Maritime SAC, Solent and Southampton Water SPA, Portsmouth Harbour SPA and Chichester and Langstone Harbours SPA. The Solent is a complex site encompassing a major estuarine system on the south coast of England. The Solent and its inlets are unique in Britain and Europe for their hydrographic regime with double tides, as well as for the complexity of the marine and estuarine habitats present within the area. Sediment habitats within the estuaries include extensive areas of intertidal mudflats, often supporting eelgrass Zostera spp. and green algae, saltmarshes and natural shoreline transitions, such as drift line vegetation. All four species of cordgrass found within the UK are present within the Solent and it is one of only two UK sites with significant amounts of the native small cordgrass Spartina maritima. The rich intertidal mudflats, saltmarsh, shingle beaches and adjacent coastal habitats, including grazing marsh, reedbeds and damp woodland, support nationally and internationally important numbers of migratory and over-wintering waders and waterfowl as well as important breeding gull and tern populations.
Issues8 Mitigation measures 1 Public access / Many human activities in the area can disturb birds. Reduce disturbance disturbance This includes activities such as: walking; dog walking; through access bird watching; boating; kayaking; kite surfing; hang management, gliding; paramotors; jet skis; wildfowling; model awareness raising helicopters/aircraft; boat mooring, and Hovercraft. and wardening Recreational activities can also affect annual vegetation of drift lines and the vegetation of stony banks. 2 Coastal Habitats are being lost as they are squeezed between Investigate options squeeze rising sea levels and hard coastal defences that are to create alternative maintained. There is a direct impact due to loss of the habitat SAC habitats such as saltmarsh. There is also an impact on birds due to the loss of habitat for feeding, roosting and breeding. In some areas, rising sea levels will result in coastal grasslands being lost to more saline grasslands, thus losing habitat for some breeding waders of the waterbird assemblage. 3 Fisheries: Dredges (inc. Hydraulic), Benthic trawls and seines Introduce commercial and Shore-based activities are categorised as 'Red’ appropriate marine and for these interest features and specifically the sub- management estuarine features: Intertidal muddy sand communities; Subtidal measures where eelgrass Zostera marina beds. required and ensure Towed gear, hand gathering of shellfish, bait digging compliance and aquaculture are the main fishery activities in this site. 4 Water pollution Water pollution affects a range of habitat and bird Implement actions in species at the site through eutrophication and toxicity. the Diffuse Water Sources include both point source discharges Pollution Plan, and (including flood alleviation / storm discharges) and investigate further diffuse water pollution from agriculture / road runoff, pollution
8 Identified in the Natural England Site Improvement Plan; in priority order
34 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
as well as historic contamination of marine sediments, primarily from copper and Tributyltin. Environment Agency flood event discharge consents allow untreated waters to be discharged which end up in the SAC and are likely to have a negative impact. There is a threat of spillage from Oil Transportation and Transfer and by the usage by Ships & Pilotage. 5 Changes in Many waders and wildfowl are decreasing in the Investigate the species Solent probably as they move north and east under causes of change distribution national trends. Some fish, such as Sand eels, may be moving their breeding grounds resulting in less food availability for breeding terns. Invertebrate populations in the intertidal muds are changing and this may disadvantage some wintering wader species. Desmoulin's Whorl Snail has decreased dramatically. Areas of salt-marsh are eroding and decreasing resulting in decreasing breeding gulls and terns as their habitat decreases and decreasing plant species of salt-marshes. 6 Climate change Climate change has impacts upon coastal species, in Investigate the that gull and tern colonies are more frequently effects of climate washed out with raising sea levels when storm surges change cause flooding to habitats. 7 Change to site There is an increasing loss of salt-marsh in much of Investigate the conditions the Solent for reasons unknown, and this needs to be reasons for change investigated. 8 Invasive The highest risk pathways through which marine Implement the species INNS are introduced and then spread have been management options identified as: commercial shipping (through release of to control invasive ballast water, and biofouling on hulls); recreational non-native species boating (through biofouling on hulls); aquaculture (INNS) (through contamination of imported or moved stock - or escaped stock in the case of the pacific oyster), and natural dispersal. 9 Direct land-take Private sea defences are causing disruption to the Option appraisal for from natural processes of allowing erosion to move private coastal development sediments around the SAC. defences 10 Biological Gull egg collecting occurs in some places, and Appropriate egg resource use wildfowling occurs in several places. These activities collection licensing are likely to be disturbing to breeding and wintering birds even though they are currently licensed / consented. 11 Change in Changes to land management are likely to occur in Ensure appropriate land areas where tidal flaps/sluices are altered and this ditch management, management results in changes to water levels or salinity of that and assess the land. Some sluices are failing, which may also result effects of tidal sluice in changes to water levels or salinity of land. Some operation ditches and drains are neglected and this can cause difficulties in land management, resulting in changes. 12 Inappropriate Predator control is decreasing, resulting in increased Increase control of pest control predation by foxes etc. and this is the likely cause of foxes decrease in successful breeding of gulls and terns. 13 Air pollution: Nitrogen deposition exceeds site relevant critical Reduce the impacts impact of loads. Locally observed effects are unknown. of air pollution
35 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
atmospheric nitrogen deposition 14 Hydrological Percolation of sea water through sea walls is causing Review abstraction changes saline intrusion into non-saline grassland habitats and licenses changing them. 15 Direct impact Off-roading is causing damage to some areas of Assess the activities from 3rd party grassland. Private sea defences are causing and their effects disruption to the natural movement processes of natural materials along the coast. Military helicopters cause disturbance to wintering birds. House boats are unlicenced and have the potential to cause damage to intertidal habitats. Fly grazing is causing issues affecting large areas of Chichester Harbour. 16 Extraction: Shingle extraction for aggregates may have an Investigate the non-living adverse impact upon intertidal fauna and flora, and extent and impact of resources may affect the movement of coastal sediments that shingle extraction would in turn have an impact upon intertidal habitats.
36 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Appendix 9: Classifying no negative effects on European Sites
Guidance on Habitats Regulations Appraisal of plans – Classifying No Negative Effect Options / policies that will not themselves lead to development e.g. because A1 they relate to design or other qualitative criteria for development, or they are not a land use planning policy. Options / policies intended to protect the natural environment, including A2 biodiversity Options / policies intended to conserve or enhance the natural, built or historic A3 environment, where enhancement measures will not be likely to have any negative effect on a European Site Options / policies that positively steer development away from European sites A4 and associated sensitive areas General policy statements or policies that only express general intentions or A5 political aspirations. Category Next Policy Comment A? stage? Policy 1 The distinctive landscape Conserving character of Chichester Harbour and Enhancing Area of Outstanding Natural General policy the Landscape Beauty will continue to be A5 NO statement conserved and enhanced for the benefit of current and future generations.
Policy 2 All development in Chichester Development Harbour will continue to Management conserve and enhance the Area of Outstanding Natural Beauty and be consistent with all other designations. Determinations on applications for planning permission and forms of consent will be consistent with the relevant policies of the relevant adopted Local Plan. General policy A1 NO Development outside of the Area statement of Outstanding Natural Beauty, but sufficiently close to the boundary, will not detrimentally impact the character and setting of the protected landscape. Mitigation for recreational disturbance will be sought for all new developments within 5.6 kilometres of the Special Protection Area.
Supported by The Chichester Harbour General policy 18 Planning Planning Principles are designed A5 NO statement though a Principles to help applicants understand number of the
37 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
the criteria against which Planning Principles planning applications will be help to address issues assessed in and around identified in the SIP Chichester Harbour AONB by Chichester Harbour Conservancy. The Planning Principles will be used to decide whether or not to raise an objection to any given planning application.
Policy 3 The richness of the Harbour’s Diversity of natural habitats will continue to Habitats be conserved, restored and enhanced so wildlife can thrive and ecological systems remain healthy and valued. Aside from Will support the natural processes, there will be A2 NO conservation of no net area loss of habitats in European sites Chichester Harbour. With regards to any relevant new developments, the statutory obligation for net environment gains will be implemented.
Policy 4 Safety Chichester Harbour on the Water Conservancy will undertake and regulate marine operations in a way that safeguards the Limited in scope but may support the Harbour, its users, the public A3 NO conservation of and the environment, by European sites implementing and demonstrating compliance with the Port Marine Safety Code.
Policy 5 Chichester Harbour The intent is to allow a Facilitating Conservancy will continue to port to function but the Navigation conserve the Harbour so that it policy may support the conservation of is fit for use as a Trust Port. European sites The A1 NO Users will be provided with intent is to allow a port adequate information about to function but the conditions in the Harbour. policy may support the conservation of European sites
38 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Policy 6 Water The water of Chichester Harbour Quality will be appropriate to the high conservation value and recreational use of the Area of Outstanding Natural Beauty. Work will continue to manage Will support the sources of water pollution. A2 NO conservation of Waste reception facilities will European sites continue to be provided and oil spill response preparedness will be maintained. Research into pollution, including microplastics, will be undertaken.
Policy 7 The farms and water catchments Catchment surrounding Chichester Harbour Sensitive are the dominant landform of the Farming Area of Outstanding Natural May support the Beauty. They will continue to be A3 NO conservation of sustainably managed to protect European sites the nationally important landscape designation and promote biodiversity
Policy 8 The abundant wildlife and plants Thriving of Chichester Harbour will Wildlife continue to be cherished, respected, allowed space to Will support the A2 NO conservation of flourish, and will live in harmony European sites with humans. Ongoing species research will continue to help inform management decisions.
Policy 9 Health Chichester Harbour will continue and Wellbeing to be recognised as an exceptional place for people undertake outdoor exercise. The landscape will continue to be enjoyed by walkers, cyclists, General policy sailors and boaters, with statement – opportunities available to try disturbance through A5 NO water sports, like kayaking, access is an issue but canoeing, stand-up the policy is modified paddleboarding and rowing in to respect nature. ways that respect nature. For many others, the chance to simply rest and relax in an Area of Outstanding Natural Beauty will benefit everyday wellbeing.
39 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Policy 10 Chichester Harbour is one of the Enjoying busiest recreational harbours in Sailing and the country. The estuary will General policy A5 NO Boating continue to be managed for the statement peaceful enjoyment of sailing and boating.
Policy 11 The stunning estuary of Excellence in Chichester Harbour is a place Education where people of all ages and abilities can develop an understanding and appreciation of one of England’s most cherished landscapes. The General policy A5 NO Chichester Harbour Education statement Service will continue to work with visiting schools and colleges, thereby enabling children and young people to learn about the Area of Outstanding Natural Beauty.
Policy 12 Local communities are Connecting fundamentally important to People with Chichester Harbour and the Nature long-term protection of the Area of Outstanding Natural Beauty. Will support the Chichester Harbour will continue A3 NO conservation of to be a place where people European sites develop positive relationships with the natural environment, thereby fostering a long-term sense of guardianship.
Policy 13 Chichester Harbour will continue Prosperous to be a place where marine Economy businesses prosper. Everyday Will support the working practices respect the conservation of importance of the Area of A4 NO European sites and Outstanding Natural Beauty help to address issues designation and the range of identified in the SIP other environmental and historic designations.
Policy 14 Global marine litter pollution has Marine Litter increased substantially in recent Pollution years, with a high level of public awareness. Chichester Harbour Will support the will continue to be part of the A2 NO conservation of solution by maintaining the European sites coastal countryside befitting the Area of Outstanding Natural Beauty designation.
40 | Page CRAGGATAK Consulting www.craggatak.co.uk
Chichester Harbour Management Plan Review Independent Assessment Report
Policy 15 The landscape of Chichester Historic Harbour reflects its history. The Environment historic environment and and Heritage heritage assets of the Area of Assets Outstanding Natural Beauty will Limited in scope but may support the continue to be conserved and A3 NO conservation of enhanced in keeping with its European sites inherent value, with increased opportunities to access, better understand and appreciate the past.
41 | Page CRAGGATAK Consulting www.craggatak.co.uk